SAFIR WEALTH ADVISORS, LLC

Safir Wealth Advisors, LLC Form ADV Part 2A – Disclosure Brochure Effective: January 30, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Safir Wealth Advisors, LLC (“SWA” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (603) 430-6001. SWA is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about SWA to assist you in determining whether to retain the Advisor. Additional information about SWA and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor firm name or CRD# 285848. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about Advisory Persons of SWA. For convenience, the Advisor has combined these documents into a single disclosure document. SWA believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. SWA encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on January 15, 2025. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or our CRD# 285848. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (603) 430- 6001. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................... 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Advisory Services ...................................................................................................................... 4 A. Firm Information ............................................................................................................................................ 4 B. Advisory Services Offered .............................................................................................................................. 4 C. Client Account Management .......................................................................................................................... 5 D. Wrap Fee Programs ...................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................ 6 Item 5 – Fees and Compensation ............................................................................................................ 6 A. Fees for Advisory Services............................................................................................................................. 6 B. Fee Billing ..................................................................................................................................................... 6 C. Other Fees and Expenses ............................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................... 7 E. Compensation for Sales of Securities ............................................................................................................. 7 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 8 Item 7 – Types of Clients ......................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss .............................................. 8 A. Methods of Analysis ....................................................................................................................................... 8 B. Risk of Loss ................................................................................................................................................... 9 Item 9 – Disciplinary Information .......................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ... 10 A. Code of Ethics ............................................................................................................................................. 10 B. Personal Trading with Material Interest ........................................................................................................ 10 C. Personal Trading in Same Securities as Clients ........................................................................................... 11 D. Personal Trading at Same Time as Client .................................................................................................... 11 Item 12 – Brokerage Practices............................................................................................................... 11 A. Recommendation of Custodian[s]................................................................................................................. 11 B. Aggregating and Allocating Trades............................................................................................................... 12 Item 13 – Review of Accounts ............................................................................................................... 12 A. Frequency of Reviews ................................................................................................................................. 12 B. Causes for Reviews ..................................................................................................................................... 12 C. Review Reports ........................................................................................................................................... 12 Item 14 – Client Referrals and Other Compensation ............................................................................ 13 A. Compensation Received by SWA................................................................................................................. 13 B. Client Referrals from Promoters ................................................................................................................... 13 Item 15 – Custody .................................................................................................................................. 13 Item 16 – Investment Discretion ............................................................................................................ 13 Item 17 – Voting Client Securities ......................................................................................................... 14 Item 18 – Financial Information ............................................................................................................. 14 Form ADV Part 2B – Brochure Supplement: Safir, Edwin ................................................................... 15 Form ADV Part 2B – Brochure Supplement: Safir, Andrew ................................................................. 17 Privacy Policy ......................................................................................................................................... 21 Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 3  Item 4 – Advisory Services A. Firm Information Safir Wealth Advisors, LLC (“SWA” or the “Advisor”) is a fee-only registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). SWA is organized as a Limited Liability Company (“LLC”) under the laws of the state of New Hampshire. SWA was founded in January 2017 and is owned and operated by Edwin T. Safir (Principal and Private Wealth Advisor) and Andrew M. Safir, CFP®, CIMA®, CPWA® (Principal, Private Wealth Advisor and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SWA. B. Advisory Services Offered SWA offers investment advisory services to individuals, high net worth individuals, trusts, and estates (each referred to as a “Client”). For information regarding this Disclosure Brochure, please contact Andrew Safir (Chief Compliance Officer) at (603) 430-6001. The Advisor acts as a fiduciary to Clients, as defined under the applicable laws and regulations. As such, each recommendation made as part of the advisory services is based on the belief that the recommendation is in the Client’s best interest. SWA’s fiduciary commitment to each Client is further described in the Code of Ethics. For more information regarding the Advisor’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services SWA may provide Clients with wealth management services, which generally include a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. These services are described below. Investment Management Services – SWA provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. SWA works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. SWA will then construct a portfolio consisting of low-cost, diversified mutual funds and/or exchange- traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, and bonds, as appropriate to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. SWA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. SWA will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. SWA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. SWA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SWA may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. SWA may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 4  the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will SWA accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Service - SWA will typically provide a variety of financial planning and consulting services to Clients either as a component of wealth management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, personal savings, education savings, retirement planning, estate planning, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, and/or charitable giving programs. SWA may also refer Clients to an accountant, attorney, or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging SWA to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that defines the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – SWA, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – SWA will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. • Portfolio Construction – SWA will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – SWA will provide investment management and ongoing oversight of the Client’s investment portfolio. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 5  D. Wrap Fee Programs SWA does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by SWA. E. Assets Under Management As of December 31, 2025, SWA manages $198,182,483 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth Management fees are paid monthly in arrears pursuant to the terms of the investment advisory agreement. Wealth management fees are based on the average daily market value of assets under management during the month. Wealth management fees are based on the following schedule: Assets Under Management ($) Up to $2,500,000 Next $2,500,000 (up to $5,000,000) Next $5,000,000 (up to $10,000,000) Over $10,000,000 Annual Rate (%) 1.00% 0.80% 0.60% 0.40% The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by SWA will be independently valued by the Custodian. SWA will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services When a Client engages SWA for stand-alone financial planning services, fees are either on an hourly basis, for a fixed fee, or on an ongoing retainer. Hourly fees are charged at a fixed hourly rate of $350. Fixed fees range from $2,000 to $10,000. Ongoing retainer fees range from $6,000 to $12,000 annually. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging in these services. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective month-end date. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the average daily balance of total assets under management with SWA at the end of each month. Clients will be provided with a statement, generally monthly, from the Custodian reflecting deduction of the wealth management fee. It is the responsibility of the Client to verify the accuracy of Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 6  these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by SWA directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced by the Advisor with up to fifty percent (50%) of the expected total fee upon executing the financial planning agreement, and the balance shall be invoiced upon completion of the agreed-upon deliverable[s]. Financial planning fees for ongoing financial planning engagements are invoiced by the Advisor on a monthly basis in arrears. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties other than SWA in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. The investment advisory fee charged by SWA is separate and distinct from these custody and execution fees. In addition, all fees paid to SWA for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of SWA, but would not receive the services provided by SWA which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by SWA to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services SWA is compensated for its wealth management services after services are rendered each month. Either party may terminate the investment advisory agreement by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services SWA may require an advance deposit for project-based planning engagements, as described above. For ongoing retainer engagements, SWA is compensated monthly in arrears. Either party may terminate the financial planning agreement by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. For hourly engagements, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate. For fixed project fee engagements, the Client shall be charged based on the percentage of the engagement scope completed by the Advisor. For ongoing planning engagements, the Client shall be charged for the number of days in the current monthly period up to the effective date of termination. Any pre-paid financial planning fees exceeding the amount due to the Advisor for services rendered shall be promptly refunded to the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities SWA does not buy or sell securities and does not receive any compensation for securities transactions in any Client account other than the investment advisory fees noted above. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 7  Item 6 – Performance-Based Fees and Side-By-Side Management SWA does not charge performance-based fees for its investment advisory services. The fees charged by SWA are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. SWA does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients SWA offers investment advisory services to individuals, high net worth individuals, trusts, and estates. The amount of each type of Client is available on SWA’s Form ADV Part 1A. SWA generally does not impose a minimum account size for establishing a relationship. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis SWA employs fundamental, technical, cyclical, and charting analysis methods in developing investment strategies for its Clients. Research and analysis from SWA are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to Clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that SWA will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company-specific) level, rather than the overall fundamental analysis of the health of the particular company that SWA is recommending. The risks with cyclical analysis are similar to those of technical analysis. Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the technical and charting analysis may lose value and may have negative investment performance. The Advisor monitors these market indicators to determine if adjustments to strategic allocations are appropriate. As noted above, SWA generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. SWA will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, SWA may also Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 8  buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, asset class, or due to market conditions. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. SWA will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, health, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETF Risks Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increases at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 9  mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Stocks There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stock” In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies (“large cap”) tend to be safer than smaller start-up companies (“small cap”) are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Bonds Corporate debt securities (or “bonds”) are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving SWA or any of its management persons. SWA and its Supervised Persons value the trust Clients place in the Advisor. The Advisor encourages all Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285848. Item 10 – Other Financial Industry Activities and Affiliations The sole business of SWA, Edwin T. Safir, and Andrew M. Safir, CFP®, CIMA®, CPWA® is to provide investment advisory services to its Clients. Neither SWA nor its Advisory Persons are involved in other business endeavors. SWA does not maintain any affiliations with other firms other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics SWA has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with SWA (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. SWA and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of SWA’s Supervised Persons to adhere not only to the specific provisions of the Code but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (603) 430-6001. B. Personal Trading with Material Interest SWA allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. SWA does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. SWA does not have a material interest in any securities traded in Client accounts. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 10  C. Personal Trading in Same Securities as Clients SWA allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls), gifts and entertainment, outside business activities, and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material non-public information. This risk is mitigated by SWA requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While SWA allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will SWA, or any Supervised Person of SWA, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] SWA does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize SWA to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, SWA does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. While SWA does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by SWA. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. SWA may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian’s offices. SWA will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services, LLC and Fidelity Brokerage Services, LLC (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodian.” SWA maintains an institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity. SWA has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage, custody, administrative support, record keeping, technology, and related services designed to support registered investment advisors like SWA in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at nominal transaction charges. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 11  1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. SWA does not participate in soft dollar programs sponsored or offered by any broker-dealer. However, the Advisor receives certain economic benefits from Fidelity. Please see Item 14 below. 2. Brokerage Referrals -- SWA does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage -- All Clients are serviced on a “directed brokerage basis,” where SWA will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). SWA will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. SWA will execute its transactions through the Custodian as authorized by the Client. SWA may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts on the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the Principal Owners of SWA. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify SWA if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 12  Item 14 – Client Referrals and Other Compensation A. Compensation Received by SWA SWA is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. SWA may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, SWA may receive non-compensated referrals of new Clients from various third parties. Participation in Institutional Advisor Platform As noted in item 12, SWA has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity, including discounts from third-party vendors due to its custodial relationship with Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor’s recommendation of this Custodian over one that does not furnish similar software, systems support, or services. B. Client Referrals from Promoters The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion SWA typically has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by SWA. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by SWA will be in accordance with each Client's investment objectives and goals. However, the Client may elect for SWA not to have discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior approval from the Client. In all such cases, the Advisor will contact the Client and obtain approval prior to executing trades or allocating investment assets. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 13  Item 17 – Voting Client Securities SWA does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies; however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither SWA nor its management has any adverse financial situations that would reasonably impair the ability of SWA to meet all obligations to its Clients. Neither SWA nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. SWA is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 14  Form ADV Part 2B – Brochure Supplement for Edwin T. Safir Principal, Private Wealth Advisor Effective: January 30, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Edwin T. Safir (CRD# 408951) in addition to the information contained in the Safir Wealth Advisors, LLC (“SWA” or the “Advisor,” CRD# 285848) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SWA Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (603) 430-6001. Additional information about Mr. Safir is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 408951. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 15  Item 2 – Educational Background and Business Experience Edwin T. Safir, born in 1948, is dedicated to advising Clients of SWA as a Principal and Private Wealth Advisor. Mr. Safir also earned a Bachelor of Science degree in Business Administration from the University of New Hampshire in 1971. Additional information regarding Mr. Safir’s employment history is included below. Employment History: Principal, Private Wealth Advisor, Safir Wealth Advisors, LLC Financial Advisor, Coburn & Meredith, Inc. SVP Investments – Branch Mgr, Legg, Mason, Wood, Walker, Inc. 01/2017 to Present 10/2003 to 01/2017 05/1993 to 11/2003 Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Safir. Mr. Safir has never been involved in any regulatory, civil, or criminal action. There have been no lawsuits, arbitration claims, or administrative proceedings against Mr. Safir. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Safir. However, the Advisor encourages you to independently view the background of Mr. Safir on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 408951. Item 4 – Other Business Activities Mr. Safir is dedicated to the investment advisory activities of SWA’s Clients. Mr. Safir does not have any other business activities. Item 5 – Additional Compensation Mr. Safir is dedicated to the investment advisory activities of SWA’s Clients. Mr. Safir does not receive any additional forms of compensation. Item 6 – Supervision Mr. Safir serves as a Principal and Private Wealth Advisor of SWA and is supervised by Andrew M. Safir, the Chief Compliance Officer. Mr. Safir can be reached at (603) 430-6001. SWA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of SWA. Further, SWA is subject to regulatory oversight by various agencies. These agencies require registration by SWA and its Supervised Persons. As a registered entity, SWA is subject to examinations by regulators, which may be announced or unannounced. SWA is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 16  Form ADV Part 2B – Brochure Supplement for Andrew M. Safir, CFP®, CIMA®, CPWA® Principal, Private Wealth Advisor, and Chief Compliance Officer Effective: January 30, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Andrew M. Safir, CFP®, CIMA®, CPWA®, (CRD# 5951152) in addition to the information contained in the Safir Wealth Advisors, LLC (“SWA” or the “Advisor,” CRD# 285848) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SWA Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (603) 430-6001. Additional information about Mr. Safir is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 5951152. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 17  Item 2 – Educational Background and Business Experience Andrew M. Safir, CFP®, CIMA®, CPWA®, born in 1989, is dedicated to advising Clients of SWA as a Principal, Private Wealth Advisor, and Chief Compliance Officer. Mr. Safir earned a Bachelor of Arts degree in Government from Harvard University in 2012. Mr. Safir also earned a Certificate in Financial Planning from Boston University in 2015. Additional information regarding Mr. Safir’s employment history is included below. Employment History: Principal, Private Wealth Advisor, and Chief Compliance Officer, Safir Wealth Advisors, LLC Financial Advisor, Coburn & Meredith Inc. Analyst, Credit Suisse Securities, LLC 01/2017 to Present 10/2013 to 01/2017 07/2012 to 09/2013 About the CFP® Designation The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education, (2) stringent code of conduct and standards of practice, and (3) ethical requirements that govern professional engagements with clients. Currently, more than 98,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). The CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 18  CFP® professionals who fail to comply with the above standards and requirements may be subject to the CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Certified Investment Management Analyst® (CIMA®) The CIMA certification signifies that an individual has met initial and ongoing experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. To earn CIMA certification, candidates must: submit an application, pass a background check and have an acceptable regulatory history; pass an online Qualification Examination; complete an in- person or online executive education program through a Registered Education Provider; pass an online Certification Examination; Pass a second background check, and have three years of financial services experience at the time of certification. CIMA certificants must adhere to Investments & Wealth Institute’s Code of Professional Responsibility and Rules and Guidelines for the use of the Marks. CIMA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through the Investments & Wealth Institute. Certified Private Wealth Advisor® (CPWA®) The CPWA designation signifies that an individual has met initial and ongoing experience, ethical, education, and examination requirements for the professional designation, which is centered on private wealth management topics and strategies for high-net-worth clients. Prerequisites for the CPWA designation are a Bachelor’s degree from an accredited college or university or one of the following designations or licenses CIMA®, CIMC ®, CFA®, CFP®, ChFC®, or CPA license, have an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory requirements and five years of experience in financial services or delivering services to high-net-worth clients. CPWA designees have completed a rigorous educational process that includes executive education requirements and successful completion of a comprehensive examination. CPWA designees are required to adhere to the Investments & Wealth Institute Code of Professional Responsibility and Rules and Guidelines for the use of the Marks. CPWA designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through the Investments & Wealth Institute. Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Safir. Mr. Safir has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims, or administrative proceedings against Mr. Safir. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Safir. However, the Advisor encourages you to independently view the background of Mr. Safir on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 5951152. Item 4 – Other Business Activities Mr. Safir is dedicated to the investment advisory activities of SWA’s Clients. Mr. Safir does not have any other business activities. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 19  Item 5 – Additional Compensation Mr. Safir is dedicated to the investment advisory activities of SWA’s Clients. Mr. Safir does not receive any additional forms of compensation. Item 6 – Supervision Mr. Safir serves as a Principal, Private Wealth Advisor, and Chief Compliance Officer of SWA. Mr. Safir can be reached at (603) 430-6001. SWA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of SWA. Further, SWA is subject to regulatory oversight by various agencies. These agencies require registration by SWA and its Supervised Persons. As a registered entity, SWA is subject to examinations by regulators, which may be announced or unannounced. SWA is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 20  Privacy Policy Effective Date: January 30, 2026 Our Commitment to You Safir Wealth Advisors, LLC (“SWA” or the “Advisor”) is committed to safeguarding the use of personal information of our Client’s (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. SWA (also referred to as “we,” “our," and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. SWA does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, date of birth, address, and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Clients’ personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 21  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed-upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes SWA does not disclose and does not intend to disclose personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where SWA or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients SWA does not disclose and does not intend to disclose non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (603) 430-6001. Safir Wealth Advisors, LLC 63 Niblick Lane, Greenland, NH 03840 Phone: (603) 430-6001 www.safiradvisors.com Page 22